Patrick Atkinson v. Target Corporation

Summary

The United States District Court for the Middle District of Florida grants Target Corporation’s supplemental motion for attorney’s fees under Federal Rule of Civil Procedure 37(a)(5), following an earlier order awarding reasonable expenses in connection with Target’s motion to compel. The court finds the requested rates and hours reasonable and orders Patrick Atkinson, his attorney, or both to pay Target $2,200 in attorney’s fees by January 16, 2026.

Holdings

1. Target established that its $2,200 request for attorney's fees was reasonable and supported by sufficient evidence, so the supplemental motion for fees was granted.
2. The lodestar method—reasonable hours multiplied by a reasonable hourly rate—is the appropriate starting point for determining reasonable attorney's fees awarded as Rule 37(a)(5) expenses.

Questions Presented

1. Whether Target established that its requested $2,200 in attorney's fees constituted reasonable expenses recoverable under Federal Rule of Civil Procedure 37(a)(5).
2. Whether the supporting evidence sufficiently established reasonable hourly rates and reasonably expended hours.

Disposition

other